Liberty Tuition privacy notice for schools, pupils, parents and guardians

This policy was created by ELT as follows:

Creator: Programme Director
Approver: Operations Director
Date of Most Recent Review and approval: 13.11.2023

Next Review: 01.09.2024 – against potential KCSIE updates. If there are legislative or regulatory changes in the interim, this policy will be reviewed before the aforementioned date.
Should no substantive changes be required at that point, the policy will move to the next review cycle

Contact: Alexander Scott – Alex@LibertyTuition.co.uk

1. About Liberty Tuition

Liberty Tuition (we, us, our) is a registered limited company, supporting all students but placing emphasis on pupils from disadvantaged backgrounds to achieve a meaningful level of academic attainment. We provide high-quality tutors to work with pupils, increasing their subject knowledge, confidence and study skills.

2. Purpose of this privacy notice

The current version of this notice is effective from 01st January 2023.

This notice intends to make the following points clear to schools, pupils, parents and guardians about the information (data) we ask partner schools to share with us about pupils taking part in our programme and the information we collect independently:

  • why we ask our partner schools to share information with us and why we collect some additional information independently (section 3.)
  • what information we ask partner schools to share with us and what information we collect independently (section 4.)
  • where we store the information and who can access it (section 5.)
  • how long we keep the information (section 6.)
  • what information we share with other parties (section 7.)
  • our legal basis for processing the information (section 8.)
  • security of personal information (section 9.)
  • transfers outside of the EEA (section 10.)
  • how to control your information and rights (section 11.)
  • how to contact us (section 12.)

Please note that if a school partners with Liberty Tuition as part of the National Tutoring Programme (NTP), then additional documentation produced by the NTP including privacy notices and other guidance beyond that covered in this notice may be provided to the school and participating pupils and their parents separately

3. Data Purpose – why we ask our partner schools to share information with us and why we collect some additional information independently

Liberty Tuition asks our partner schools to provide information about the pupils they put forward for participation in our tutoring programme, and we collect some additional information independently, for the following reasons:

  • to effectively coordinate the delivery of our programme both in-school and online;
  • to meet safeguarding responsibilities;
  • to enable the evaluation of our impact and improve future programme delivery;
  • to demonstrate our programme reaches the pupils who need it as defined by our compnay mission.

4. Data Collection – what information we ask partner schools to share with us and what information we collect independently

Before a pupil officially joins our programme, we ask our partner schools to provide us with the following information about all pupils selected to take part, via a password-protected spreadsheet or email encryption software: full name, school, school year, gender, date of birth, unique pupil number, subject ability, pupil premium status, indication of if the pupil could access private tutoring (for non-PP eligible pupils).

  • Optionally, the school may also choose to provide additional engagement-related guidance for our consideration.
  • During the programme, we will independently record: pupil attendance and engagement, pupil assessment results, pupil survey responses.
  • After a pupil has completed the programme, we will ask our partner schools to provide, in accordance with our partnership agreement and via a password-protected spreadsheet or email encryption software: pupils’ final GCSE results in English Language and maths, or final SAT results in reading, writing and maths.
  • For pupils who are accessing the tutoring sessions online, video recordings of tutoring sessions are made.
  • We may also request parent or guardian contact details from our partner schools in order to introduce ourselves to the parents/guardians of Liberty
  • Tuition pupils, and to keep them updated on their child’s attendance where this is requested or deemed appropriate.

5. Data Storage and Access – where we store the information and who can access it

  • We operate a central database to help us securely store pupil and parent/guardian information. The database is password-protected and access to the database is limited to Liberty Tuition staff, with ‘staff’ referring to the senior leader team of Liberty Tuition and not including our tutors.
  • For pupils who are accessing the tutoring sessions online , video recordings of tutoring sessions are stored on the online tutoring platform, TutorCruncher. Access to the platform is password-protected and only Liberty Tuition staff can view session video recordings.
  • Information about pupils and their parents/guardian may also be recorded in other formats, such as in emails, word processing and spreadsheet applications. Information in these formats may be stored on Liberty Tuition devices or in Google Workspace applications such as our Google Drive cloud storage. Access to these devices and cloud applications is password-protected and restricted to Liberty Tuition staff.

6. Retention – how long we keep the information

  • We work to ensure that your personal data is only retained for the period that Liberty Tuition needs it for, or in accordance with laws, regulations and professional obligations that we are subject to.
  • Pupil and parent/guardian records on our central database containing information provided by our partner schools, alongside additional information we have captured independently, are pseudonymised approximately two academic years after a pupil graduates from the Liberty Tuition programme.
  • This involves removal of all information from a record which could be used to identify an individual pupil or their parent/guardian. This process can only be reversed by specific members of the Liberty Tuition team and only under reasonable circumstances, such as to facilitate a safeguarding enquiry.
  • Video recordings of online tutoring sessions completed on TutorCruncher are kept for approximately one full academic term after the term in which the session took place.
  • Our best practice for any pupil and parent/guardian information temporarily stored in other formats, such as word processing or spreadsheet applications, is to delete this information as soon as the purpose for processing the information in the alternative format is complete.
  • Pupil records on our central database and any related parent/guardian information are deleted or permanently anonymised 10 years after they graduate from the Liberty Tuition programme. The anonymisation process cannot be reversed.
  • If you would like to find out how long any other information is being retained, please contact us via the details provided in section 12 of this policy.

7. Data sharing – what information we share with other parties.

  • The following information about pupils may be shared with specific tutors before and during the programme to help them tailor their tutoring sessions: full name, school, school year, gender, subject ability, assessment results, attendance and engagement notes, and any other information the pupil’s school has voluntarily provided to us which is deemed relevant for the tutor to be made aware of.
  • After a pupil has completed the programme, the following information may be shared with tutors, but only in relation to those pupils they directly supported: pupils’ final GCSE results, or final SAT results in reading, writing and maths.
  • The following information about parents/guardians may be shared with specific tutors before and during the programme to help them communicate effectively during their tuition: full name, contact number, email address, address (if tuition is at the home address).
  • Unless consent is sought, or an agreement of confidentiality is in place, information about pupils or their parents/guardians will not be intentionally shared with other third parties.

8. Legal basis – our legal basis for processing the information

  • To lawfully process the information outlined in this notice, we may rely on:
  • Legitimate interests: where information we request or collect independently about pupils or their parents/guardians is used to effectively coordinate the delivery of our programme in partnership with schools, enable the evaluation of our impact, improve the future delivery of our programme, and demonstrate that our programme reaches the pupils who need it as defined by our charity’s mission. Examples: pupil full name, subject ability, pupil premium status, unique pupil number, exam results, survey responses.
  • Legal obligation: where we may need to use or share information we hold about pupils or their parents/guardians in order to comply with a legal obligation, such as to facilitate the investigation of a safeguarding concern with a local authority.
  • Consent: in order to facilitate any additional processing of information beyond which is outlined in this privacy notice, we will seek consent from the relevant individuals in order to do so.

9. Security of personal information

  • We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.
  • We have procedures to handle any potential data security breaches. Data subjects, third parties and any applicable regulators will be notified where we are legally required to do so. If you become aware of a potential data breach involving your personal data, please contact us immediately using the details provided at the end of this notice.

10. Transfers outside of the EEA

  • In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the European Economic Area (EEA).
  • We may share personal information to third parties outside of the European Economic Area (EEA). Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.
  • Where personal data is transferred outside of the EEA to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include Standard Contractual Clauses.
  • For more information about transfers and safeguarding measures, please contact us using the information in section 12.

11. How to control your information and your rights

Liberty Tuition is committed to accommodating your rights under the General Data Protection Regulation, which include:

  • Your right to be fully informed on how the information we ask you to share with us and the information we collect independently is processed by Liberty Tuition. If you have any questions about the guidance provided in this policy notice, or would like further detail on specific sections, then please address your query to the contact details provided below
  • Your right to access the information we have asked you to share with us and the information we collected independently. If you require a copy of this information, please make this request using the contact details provided in this notice and the information will be provided to you in an electronic format as soon as possible, within one month at the latest. We will need to confirm your identity to provide this information.
  • Your right to rectify the information we have asked you to share with us and the information we collected independently if it is inaccurate or incomplete. If you believe that any of the information is inaccurate or incomplete, please contact us as soon as possible using the contact details provided below. We will promptly correct any information found to be incorrect.
  • Your right to erasure:

○ The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

■   the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
■   the data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing;
■   the data subject objects to the processing and there are no overriding legitimate grounds for the processing, or the data subject
objects to the processing

■   the personal data have been unlawfully processed;
■   the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal
data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data. 
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

■   for exercising the right of freedom of expression and information;
■   for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
■   for reasons of public interest in the area of public health
■   for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
■   for the establishment, exercise or defence of legal claims.

  • Your right to restrict or object to the further processing of the information we have asked you to share with us and the information we collected independently. Please use the contact details provided to inform us of any wish to restrict or object to the further processing of this information. Note that we may need to retain some key information in order to respect your restriction or objection in future.

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

Where we make an automated decision which has a legal or substantially similar effect, you have the right to speak to us and we may then review the decision, provide a more detailed explanation and assess if the automated decision was made correctly.

12. How to contact us

To contact us in relation to any of the information contained in this policy notice, to make a complaint, to pursue any rights under the General Data Protection Regulation and to contact our DPO, please email:
info@LibertyTuition.co.uk

Contact: Programme Director, Alexander Scott
Telephone: 07845035247
Email: Info@LibertyTuition.co.uk

If you are unhappy with the way that we have handled your Personal Information, you can make a complaint to the Information Commissioner’s Office (ICO) which is the UK authority responsible for data protection.